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K a privacy professional wants to show that an organization's privacy program is working as intended, the professional should?
SCENARIO
Please use the following to answer the next QUESTION:
Martin Briseño is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseño decided to change the hotel’s on-the-job mentoring model to a standardized training program for employees who were progressing from line positions into supervisory positions. He developed a curriculum comprising a series of lessons, scenarios, and assessments, which was delivered in-person to small groups. Interest in the training increased, leading Briseño to work with corporate HR specialists and software engineers to offer the program in an online format. The online program saved the cost of a trainer and allowed participants to work through the material at their own pace.
Upon hearing about the success of Briseño’s program, Pacific Suites corporate Vice President Maryanne Silva-Hayes expanded the training and offered it company-wide. Employees who completed the program received certification as a Pacific Suites Hospitality Supervisor. By 2001, the program had grown to provide industry-wide training. Personnel at hotels across the country could sign up and pay to take the course online. As the program became increasingly profitable, Pacific Suites developed an offshoot business, Pacific Hospitality Training (PHT). The sole focus of PHT was developing and marketing a variety of online courses and course progressions providing a number of professional certifications in the hospitality industry.
By setting up a user account with PHT, course participants could access an information library, sign up for courses, and take end-of-course certification tests. When a user opened a new account, all information was saved by default, including the user’s name, date of birth, contact information, credit card information, employer, and job title. The registration page offered an opt-out choice that users could click to not have their credit card numbers saved. Once a user name and password were established, users could return to check their course status, review and reprint their certifications, and sign up and pay for new courses. Between 2002 and 2008, PHT issued more than 700,000 professional certifications.
PHT’s profits declined in 2009 and 2010, the victim of industry downsizing and increased competition from e- learning providers. By 2011, Pacific Suites was out of the online certification business and PHT was dissolved. The training program’s systems and records remained in Pacific Suites’ digital archives, un-accessed and unused. Briseño and Silva-Hayes moved on to work for other companies, and there was no plan for handling the archived data after the program ended. After PHT was dissolved, Pacific Suites executives turned their attention to crucial day-to-day operations. They planned to deal with the PHT materials once resources allowed.
In 2012, the Pacific Suites computer network was hacked. Malware installed on the online reservation system exposed the credit card information of hundreds of hotel guests. While targeting the financial data on the reservation site, hackers also discovered the archived training course data and registration accounts of Pacific Hospitality Training’s customers. The result of the hack was the exfiltration of the credit card numbers of recent hotel guests and the exfiltration of the PHT database with all its contents.
A Pacific Suites systems analyst discovered the information security breach in a routine scan of activity reports. Pacific Suites quickly notified credit card companies and recent hotel guests of the breach, attempting to prevent serious harm. Technical security engineers faced a challenge in dealing with the PHT data.
PHT course administrators and the IT engineers did not have a system for tracking, cataloguing, and storing information. Pacific Suites has procedures in place for data access and storage, but those procedures were not implemented when PHT was formed. When the PHT database was acquired by Pacific Suites, it had no owner or oversight. By the time technical security engineers determined what private information was compromised, at least 8,000 credit card holders were potential victims of fraudulent activity.
How would a strong data life cycle management policy have helped prevent the breach?
Which is NOT an influence on the privacy environment external to an organization?
Which of the following information must be provided by the data controller when complying with GDPR “right to be informed” requirements?
SCENARIO
Please use the following to answer the next QUESTION:
Perhaps Jack Kelly should have stayed in the U.S. He enjoys a formidable reputation inside the company, Special Handling Shipping, for his work in reforming certain "rogue" offices. Last year, news broke that a police sting operation had revealed a drug ring operating in the Providence, Rhode Island office in the United States. Video from the office's video surveillance cameras leaked to news operations showed a drug exchange between Special Handling staff and undercover officers.
In the wake of this incident, Kelly had been sent to Providence to change the "hands off" culture that upper management believed had let the criminal elements conduct their illicit transactions. After a few weeks under Kelly's direction, the office became a model of efficiency and customer service. Kelly monitored his workers' activities using the same cameras that had recorded the illegal conduct of their former co-workers.
Now Kelly has been charged with turning around the office in Cork, Ireland, another trouble spot. The company has received numerous reports of the staff leaving the office unattended. When Kelly arrived, he found that even when present, the staff often spent their days socializing or conducting personal business on their mobile phones. Again, he observed their behaviors using surveillance cameras. He issued written reprimands to six staff members based on the first day of video alone.
Much to Kelly's surprise and chagrin, he and the company are now under investigation by the Data Protection Commissioner of Ireland for allegedly violating the privacy rights of employees. Kelly was told that the company's license for the cameras listed facility security as their main use, but he does not know why this matters. He has pointed out to his superiors that the company's training programs on privacy protection and data collection mention nothing about surveillance video.
You are a privacy protection consultant, hired by the company to assess this incident, report on the legal and compliance issues, and recommend next steps.
Knowing that the regulator is now investigating, what would be the best step to take?
An organization’s internal audit team should do all of the following EXCEPT?
(As the data protection officer for the growing company. Vision 4634. what would be the most cost-effective way to monitor changes in laws and regulations?)
Which of the following is NOT an important factor to consider when developing a data retention policy?
SCENARIO
Please use the following to answer the next QUESTION:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space’s practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.
Penny’s colleague in Marketing is excited by the new sales and the company’s plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her “I heard someone in the breakroom talking about some new privacy laws but I really don’t think it affects us. We’re just a small company. I mean we just sell accessories online, so what’s the real risk?” He has also told her that he works with a number of small companies that help him get projects completed in a hurry. “We’ve got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don’t have.”
In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny’s colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team “didn’t know what to do or who should do what. We hadn’t been trained on it but we’re a small team though, so it worked out OK in the end.” Penny is concerned that these issues will compromise Ace Space’s privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data “shake up”. Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space’s CEO today and has been asked to give her first impressions and an overview of her next steps.
To help Penny and her CEO with their objectives, what would be the most helpful approach to address her IT concerns?
If your organization has a recurring issue with colleagues not reporting personal data breaches, all of the following are advisable to do EXCEPT?
What is least likely to be achieved by implementing a Data Lifecycle Management (DLM) program?
If done correctly, how can a Data Protection Impact Assessment (DPIA) create a win/win scenario for organizations and individuals?
SCENARIO
Please use the following to answer the next QUESTION:
It's just what you were afraid of. Without consulting you, the information technology director at your organization launched a new initiative to encourage employees to use personal devices for conducting business. The initiative made purchasing a new, high-specification laptop computer an attractive option, with discounted laptops paid for as a payroll deduction spread over a year of paychecks. The organization is also paying the sales taxes. It's a great deal, and after a month, more than half the organization's employees have signed on and acquired new laptops. Walking through the facility, you see them happily customizing and comparing notes on their new computers, and at the end of the day, most take their laptops with them, potentially carrying personal data to their homes or other unknown locations. It's enough to give you data- protection nightmares, and you've pointed out to the information technology Director and many others in the organization the potential hazards of this new practice, including the inevitability of eventual data loss or theft.
Today you have in your office a representative of the organization's marketing department who shares with you, reluctantly, a story with potentially serious consequences. The night before, straight from work, with laptop in hand, he went to the Bull and Horn Pub to play billiards with his friends. A fine night of sport and socializing began, with the laptop "safely" tucked on a bench, beneath his jacket. Later that night, when it was time to depart, he retrieved the jacket, but the laptop was gone. It was not beneath the bench or on another bench nearby. The waitstaff had not seen it. His friends were not playing a joke on him. After a sleepless night, he confirmed it this morning, stopping by the pub to talk to the cleanup crew. They had not found it. The laptop was missing. Stolen, it seems. He looks at you, embarrassed and upset.
You ask him if the laptop contains any personal data from clients, and, sadly, he nods his head, yes. He believes it contains files on about 100 clients, including names, addresses and governmental identification numbers. He sighs and places his head in his hands in despair.
In order to determine the best course of action, how should this incident most productively be viewed?
Which of the documents below assists the Privacy Manager in identifying and responding to a request from an individual about what personal information the organization holds about then with whom the information is shared?
The first step an organization should take when considering the use of a third-party's AI-based resume ranking tool is to?
SCENARIO
Please use the following lo answer the next question:
You are the privacy manager within the privacy office of a National Forest Parks and Recreation Department. While having lunch with a colleague from the IT division, you learn that the IT director has put out a request for proposal (RFP) which calls for a system that collects the personal data of park attendees.
You consult with a few other colleagues in IT and learn that the RFP is worded such that it leaves it to the vendors to demonstrate what information they would collect from people who enter parks anywhere in the country, either in a vehicle or on foot. A partial list of the information collected includes:
• personal identifiers such as name, address, age, gender;
• vehicle registration information:
• facial images of park attendees;
• health information (e.g.. physical disabilities, use of mobility devices)
The stated purpose of the RFP is to:
"Improve the National Forest. Parks, and Recreation Department's ability to track and monitor service usage thereby Increasing the robustness of our customer data and to improve service offerings.''
Companies have already started submitting proposals for software solutions that address these information gathering practices. There is only one week left before the RFP closes.
The IT department has put together an RFP evaluation team but no one from the privacy office has been a Dart of the RFP ud to this point. This occurred deposite the fact….
From a privacy management perspective, what is problematic about the "stated purpose" of the RFP?
With whom would it be best for a privacy professional in an organization to consult regarding Privacy-Enhancing Technologies (PETs)?
Which statement is FALSE regarding the use of technical security controls?
A Privacy Threshold Analysis (PTA), Privacy Impact Assessment (PIA) and Data Protection Impact Assessment (DPIA) are conducted during what phase of a System Development Life Cycle (SDLC)?
Your company's lead applied scientist believes there's an opportunity to proactively address customer issues using machine learning. She requests access to all of the company's customer data and several publicly available datasets
All the following are appropriate next steps EXCEPT?
SCENARIO
Please use the following to answer the next question:
The risk committee of your organization is particularly concerned not only by the number and frequency of data breaches reported to it over the past 12 months, but also the inconsistency in responses and poor incident response turnaround times.
Upon reviewing the current incident response plan (IRP), it was discovered that while the business continuity plan (BCP) had been updated on time, the IRP, linked to the BCP, was last updated over three years ago.
What additional procedure and/or process would best reduce future incidents?
(All of the following are the responsibilities of the privacy professional EXCEPT?)
SCENARIO
Please use the following to answer the next QUESTION:
Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has found some degree of disorganization after touring the company headquarters. His uncle Henry had always focused on production – not data processing – and Anton is concerned. In several storage rooms, he has found paper files, disks, and old computers that appear to contain the personal data of current and former employees and customers. Anton knows that a single break-in could irrevocably damage the company's relationship with its loyal customers. He intends to set a goal of guaranteed zero loss of personal information.
To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the company. However, Kenneth – his uncle's vice president and longtime confidante – wants to hold off on Anton's idea in favor of converting any paper records held at the company to electronic storage. Kenneth
believes this process would only take one or two years. Anton likes this idea; he envisions a password- protected system that only he and Kenneth can access.
Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware store down the street will be responsible for their own information management. Then, any unneeded subsidiary data still in Anton's possession can be destroyed within the next few years.
After learning of a recent security incident, Anton realizes that another crucial step will be notifying customers. Kenneth insists that two lost hard drives in Question are not cause for concern; all of the data was encrypted and not sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all employees and customers to be safe.
Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago, but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning another trusted employee with a law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should be safe for another five years, at which time he can order another check.
Documentation of this analysis will show auditors due diligence.
Anton has started down a long road toward improved management of the company, but he knows the effort is worth it. Anton wants his uncle's legacy to continue for many years to come.
In terms of compliance with regulatory and legislative changes, Anton has a misconception regarding?
SCENARIO
Please use the following lo answer the next question:
You are the privacy manager within the privacy office of a National Forest Parks and Recreation Department. While having lunch with a colleague from the IT division, you learn that the IT director has put out a request for proposal (RFP) which calls for a system that collects the personal data of park attendees.
You consult with a few other colleagues in IT and learn that the RFP is worded such that it leaves it to the vendors to demonstrate what information they would collect from people who enter parks anywhere in the country, either in a vehicle or on foot. A partial list of the information collected includes:
• personal identifiers such as name, address, age, gender;
• vehicle registration information:
• facial images of park attendees;
• health information (e.g.. physical disabilities, use of mobility devices)
The stated purpose of the RFP is to:
"Improve the National Forest. Parks, and Recreation Department's ability to track and monitor service usage thereby Increasing the robustness of our customer data and to improve service offerings.''
Companies have already started submitting proposals for software solutions that address these information gathering practices. There is only one week left before the RFP closes.
The IT department has put together an RFP evaluation team but no one from the privacy office has been a Dart of the RFP ud to this point. This occurred deposite the fact….
All of the following are appropriate for the privacy office in developing a privacy assessment metric EXCEPT?
SCENARIO
Please use the following to answer the next QUESTION:
Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has found some degree of disorganization after touring the company headquarters. His uncle Henry had always focused on production – not data processing – and Anton is concerned. In several storage rooms, he has found paper files, disks, and old computers that appear to contain the personal data of current and former employees and customers. Anton knows that a single break-in could irrevocably damage the company's relationship with its loyal customers. He intends to set a goal of guaranteed zero loss of personal information.
To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the company. However, Kenneth – his uncle's vice president and longtime confidante – wants to hold off on Anton's idea in favor of converting any paper records held at the company to electronic storage. Kenneth believes this process would only take one or two years. Anton likes this idea; he envisions a password- protected system that only he and Kenneth can access.
Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware store down the street will be responsible for their own information management. Then, any unneeded
subsidiary data still in Anton's possession can be destroyed within the next few years.
After learning of a recent security incident, Anton realizes that another crucial step will be notifying customers. Kenneth insists that two lost hard drives in Question are not cause for concern; all of the data was encrypted and not sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all employees and customers to be safe.
Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago, but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning another trusted employee with a law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should be safe for another five years, at which time he can order another check.
Documentation of this analysis will show auditors due diligence.
Anton has started down a long road toward improved management of the company, but he knows the effort is worth it. Anton wants his uncle's legacy to continue for many years to come.
What would the company's legal team most likely recommend to Anton regarding his planned communication with customers?
Formosa International operates in 20 different countries including the United States and France. What organizational approach would make complying with a number of different regulations easier?
“Collection”, “access” and “destruction” are aspects of what privacy management process?
(Which of the following actions should be pnoritized to ensure continuous compliance with the new phvacy law?)
SCENARIO
Please use the following to answer the next QUESTION:
For 15 years, Albert has worked at Treasure Box – a mail order company in the United States (U.S.) that used to sell decorative candles around the world, but has recently decided to limit its shipments to customers in the 48 contiguous states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not being promoted, coupled with his recent interest in issues of privacy protection, have motivated Albert to be an agent of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives aware of lapses in the company’s privacy program. He feels certain he will be rewarded with a promotion for preventing negative consequences resulting from the company’s outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA (Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful way to measure Treasure Box’s ability to protect personal data. Albert has noticed that Treasure Box fails to meet the requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company with meeting this level in order to provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company’s commitment to the security of customer and employee personal data against external threats. However, Albert worries about the high turnover rate within the company, particularly in the area of direct phone marketing. He sees many unfamiliar faces every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours and low pay, as well as what seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two recent security incidents. The company has responded to the incidents with internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence indicates that many people still harbor mistrust. Albert wants to help the company recover. He knows there is at least one incident the public in unaware of, although Albert does not know the details. He believes the company’s insistence on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company’s recent business maneuvers will also impress the interviewers. For example, Albert is aware of the company’s intention to acquire a medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.
Based on Albert’s observations regarding recent security incidents, which of the following should he suggest as a priority for Treasure Box?
(Which of the following should be your first step when conducting an internal privacy audit focused on identifying cross-border data transfers in cloud environments?)
Which of the following best demonstrates the effectiveness of a firm’s privacy incident response process?
Your marketing team wants to know why they need a check box for their SMS opt-in. You explain it is part of the consumer's right to?
Under the General Data Protection Regulation (GDPR), international data transfer is allowed using the mechanisms in all of the following scenarios EXCEPT between companies who?
SCENARIO
Please use the following to answer the next QUESTION:
Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments. After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.
The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.
Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.
In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the
product. This data is all stored in the cloud and is encrypted both during transmission and at rest.
Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.
What can Sanjay do to minimize the risks of offering the product in Europe?
SCENARIO
Please use the following to answer the next QUESTION:
Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last week, a data processing firm used by the company reported that its system may have been hacked, and customer data such as names, addresses, and birthdays may have been compromised. Although the attempt was proven unsuccessful, the scare has prompted several Nationwide Grill executives to Question the company's privacy program at today's meeting.
Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if there had been an actual breach, the chances of a successful suit against the company were slim. But Alice remained unconvinced.
Spencer – a former CEO and currently a senior advisor – said that he had always warned against the use of contractors for data processing. At the very least, he argued, they should be held contractually liable for telling
customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company name for a problem it did not cause.
One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason. "Breaches can happen, despite organizations' best efforts," she remarked. "Reasonable preparedness is key." She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of cultivating relationships, Haley was able to successfully manage the company's incident response.
Spencer replied that acting with reason means allowing security to be handled by the security functions within the company – not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters, emails, and memos from both HR and the ethics department related to the company's privacy program. Both the volume and the duplication of information means that it is often ignored altogether.
Spencer said, "The company needs to dedicate itself to its privacy program and set regular in-person trainings for all staff once a month."
Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.
How could the objection to Spencer's training suggestion be addressed?
Which of the following would be least beneficial in integrating privacy requirements and representation into functional areas across an organization?
An organization's privacy officer was just notified by the benefits manager that she accidentally sent out the retirement enrollment report of all employees to a wrong vendor.
Which of the following actions should the privacy officer take first?
A new business crafting its privacy policy is struggling with how it will define the term "personal data."
Which of the following should inform this decision?
Under the General Data Protection Regulation (GDPR), when would a data subject have the right to require the erasure of his or her data without undue delay?
SCENARIO
Please use the following to answer the next QUESTION:
You lead the privacy office for a company that handles information from individuals living in several countries throughout Europe and the Americas. You begin that morning’s privacy review when a contracts officer sends you a message asking for a phone call. The message lacks clarity and detail, but you presume that data was lost.
When you contact the contracts officer, he tells you that he received a letter in the mail from a vendor stating that the vendor improperly shared information about your customers. He called the vendor and confirmed that your company recently surveyed exactly 2000 individuals about their most recent healthcare experience and sent those surveys to the vendor to transcribe it into a database, but the vendor forgot to encrypt the database as promised in the contract. As a result, the vendor has lost control of the data.
The vendor is extremely apologetic and offers to take responsibility for sending out the notifications. They tell you they set aside 2000 stamped postcards because that should reduce the time it takes to get the notice in the mail. One side is limited to their logo, but the other side is blank and they will accept whatever you want to write. You put their offer on hold and begin to develop the text around the space constraints. You are content to let the vendor’s logo be associated with the notification.
The notification explains that your company recently hired a vendor to store information about their most recent experience at St. Sebastian Hospital’s Clinic for Infectious Diseases. The vendor did not encrypt the information and no longer has control of it. All 2000 affected individuals are invited to sign-up for email notifications about their information. They simply need to go to your company’s website and watch a quick advertisement, then provide their name, email address, and month and year of birth.
You email the incident-response council for their buy-in before 9 a.m. If anything goes wrong in this situation, you want to diffuse the blame across your colleagues. Over the next eight hours, everyone emails their comments back and forth. The consultant who leads the incident-response team notes that it is his first day with the company, but he has been in other industries for 45 years and will do his best. One of the three lawyers on the council causes the conversation to veer off course, but it eventually gets back on track. At the end of the day, they vote to proceed with the notification you wrote and use the vendor’s postcards.
Shortly after the vendor mails the postcards, you learn the data was on a server that was stolen, and make the decision to have your company offer credit monitoring services. A quick internet search finds a credit monitoring company with a convincing name: Credit Under Lock and Key (CRUDLOK). Your sales rep has never handled a contract for 2000 people, but develops a proposal in about a day which says CRUDLOK will:
1.Send an enrollment invitation to everyone the day after the contract is signed.
2.Enroll someone with just their first name and the last-4 of their national identifier.
3.Monitor each enrollee’s credit for two years from the date of enrollment.
4.Send a monthly email with their credit rating and offers for credit-related services at market rates.
5.Charge your company 20% of the cost of any credit restoration.
You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three days later you sit down and document all that went well and all that could have gone better. You put it in a file to reference the next time an incident occurs.
Which of the following elements of the incident did you adequately determine?
SCENARIO
Please use the following to answer the next QUESTION:
Martin Briseño is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseño decided to change the hotel’s on-the-job mentoring model to a standardized training program for employees who were progressing from line positions into supervisory positions. He developed a curriculum comprising a series of lessons, scenarios, and assessments, which was delivered in-person to small groups. Interest in the training increased, leading Briseño to work with corporate HR specialists and software engineers to offer the program in an online format. The online program saved the cost of a trainer and allowed participants to work through the material at their own pace.
Upon hearing about the success of Briseño’s program, Pacific Suites corporate Vice President Maryanne Silva-Hayes expanded the training and offered it company-wide. Employees who completed the program received certification as a Pacific Suites Hospitality Supervisor. By 2001, the program had grown to provide industry-wide training. Personnel at hotels across the country could sign up and pay to take the course online. As the program became increasingly profitable, Pacific Suites developed an offshoot business, Pacific Hospitality Training (PHT). The sole focus of PHT was developing and marketing a variety of online courses and course progressions providing a number of professional certifications in the hospitality industry.
By setting up a user account with PHT, course participants could access an information library, sign up for courses, and take end-of-course certification tests. When a user opened a new account, all information was saved by default, including the user’s name, date of birth, contact information, credit card information, employer, and job title. The registration page offered an opt-out choice that users could click to not have their credit card numbers saved. Once a user name and password were established, users could return to check their course status, review and reprint their certifications, and sign up and pay for new courses. Between 2002 and 2008, PHT issued more than 700,000 professional certifications.
PHT’s profits declined in 2009 and 2010, the victim of industry downsizing and increased competition from e- learning providers. By 2011, Pacific Suites was out of the online certification business and PHT was dissolved. The training program’s systems and records remained in Pacific Suites’ digital archives, un-accessed and unused. Briseño and Silva-Hayes moved on to work for other companies, and there was no plan for handling the archived data after the program ended. After PHT was dissolved, Pacific Suites executives turned their attention to crucial day-to-day operations. They planned to deal with the PHT materials once resources allowed.
In 2012, the Pacific Suites computer network was hacked. Malware installed on the online reservation system exposed the credit card information of hundreds of hotel guests. While targeting the financial data on the reservation site, hackers also discovered the archived training course data and registration accounts of Pacific Hospitality Training’s customers. The result of the hack was the exfiltration of the credit card numbers of recent hotel guests and the exfiltration of the PHT database with all its contents.
A Pacific Suites systems analyst discovered the information security breach in a routine scan of activity reports. Pacific Suites quickly notified credit card companies and recent hotel guests of the breach, attempting to prevent serious harm. Technical security engineers faced a challenge in dealing with the PHT data.
PHT course administrators and the IT engineers did not have a system for tracking, cataloguing, and storing information. Pacific Suites has procedures in place for data access and storage, but those procedures were not implemented when PHT was formed. When the PHT database was acquired by Pacific Suites, it had no owner or oversight. By the time technical security engineers determined what private information was compromised, at least 8,000 credit card holders were potential victims of fraudulent activity.
In the Information Technology engineers had originally set the default for customer credit card information to “Do Not Save,” this action would have been in line with what concept?
SCENARIO
Please use the following to answer the next QUESTION:
For 15 years, Albert has worked at Treasure Box – a mail order company in the United States (U.S.) that used to sell decorative candles around the world, but has recently decided to limit its shipments to customers in the 48 contiguous states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not being promoted, coupled with his recent interest in issues of privacy protection, have motivated Albert to be an agent of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives aware of lapses in the company’s privacy program. He feels certain he will be rewarded with a promotion for preventing negative consequences resulting from the company’s outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA (Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful way to measure Treasure Box’s ability to protect personal data. Albert has noticed that Treasure Box fails to meet the requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company with meeting this level in order to provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company’s commitment to the security of customer and employee personal data against external threats. However, Albert worries about the high turnover rate within the company, particularly in the area of direct phone marketing. He sees many unfamiliar faces every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours and low pay, as well as what seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two recent security incidents. The company has responded to the incidents with internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence indicates that many people still harbor mistrust. Albert wants to help the company recover. He knows there is at least one incident the public in unaware of, although Albert does not know the details. He believes the company’s insistence on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company’s recent business maneuvers will also impress the interviewers. For example, Albert is aware of the company’s intention to acquire a medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.
Based on Albert’s observations, executive leadership should most likely pay closer attention to what?
Which of the following is the most likely way an independent privacy organization might work to promote sound privacy practices?
SCENARIO
Please use the following to answer the next QUESTION:
Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments. After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.
The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.
Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.
In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the product. This data is all stored in the cloud and is encrypted both during transmission and at rest.
Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.
What step in the system development process did Manasa skip?
“Respond” in the privacy operational lifecycle includes which of the following?
When building a data privacy program, what is a good starting point to understand the scope of privacy program needs?
SCENARIO
Please use the following to answer the next QUESTION:
John is the new privacy officer at the prestigious international law firm – A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & Acquisition in both U.S. and Europe.
During lunch with a colleague from the Information Technology department, John heard that the Head of IT, Derrick, is about to outsource the firm's email continuity service to their existing email security vendor – MessageSafe. Being successful as an email hygiene vendor, MessageSafe is expanding its business by leasing cloud infrastructure from Cloud Inc. to host email continuity service for A&M LLP.
John is very concerned about this initiative. He recalled that MessageSafe was in the news six months ago due to a security breach. Immediately, John did a quick research of MessageSafe's previous breach and learned that the breach was caused by an unintentional mistake by an IT administrator. He scheduled a meeting with Derrick to address his concerns.
At the meeting, Derrick emphasized that email is the primary method for the firm's lawyers to communicate with clients, thus it is critical to have the email continuity service to avoid any possible email downtime. Derrick has been using the anti-spam service provided by MessageSafe for five years and is very happy with the quality of service provided by MessageSafe. In addition to the significant discount offered by MessageSafe, Derrick emphasized that he can also speed up the onboarding process since the firm already has a service contract in place with MessageSafe. The existing on-premises email continuity solution is about to reach its end of life very soon and he doesn't have the time or resource to look for another solution. Furthermore, the off- premises email continuity service will only be turned on when the email service at A&M LLP's primary and secondary data centers are both down, and the email messages stored at MessageSafe site for continuity service will be automatically deleted after 30 days.
Which of the following is NOT an obligation of MessageSafe as the email continuity service provider for A&M LLP?
SCENARIO
Please use the following to answer the next QUESTION:
Edufox has hosted an annual convention of users of its famous e-learning software platform, and over time, it has become a grand event. It fills one of the large downtown conference hotels and overflows into the others, with several thousand attendees enjoying three days of presentations, panel discussions and networking. The convention is the centerpiece of the company's product rollout schedule and a great training opportunity for current users. The sales force also encourages prospective clients to attend to get a better sense of the ways in which the system can be customized to meet diverse needs and understand that when they buy into this system, they are joining a community that feels like family.
This year's conference is only three weeks away, and you have just heard news of a new initiative supporting it: a smartphone app for attendees. The app will support late registration, highlight the featured presentations and provide a mobile version of the conference program. It also links to a restaurant reservation system with the best cuisine in the areas featured. "It's going to be great," the developer, Deidre Hoffman, tells you, "if, that is, we actually get it working!" She laughs nervously but explains that because of the tight time frame she'd been given to build the app, she outsourced the job to a local firm. "It's just three young people," she says, "but they do great work." She describes some of the other apps they have built. When asked how they were selected for this job, Deidre shrugs. "They do good work, so I chose them."
Deidre is a terrific employee with a strong track record. That's why she's been charged to deliver this rushed project. You're sure she has the best interests of the company at heart, and you don't doubt that she's under pressure to meet a deadline that cannot be pushed back. However, you have concerns about the app's handling of personal data and its security safeguards. Over lunch in the break room, you start to talk to her
about it, but she quickly tries to reassure you, "I'm sure with your help we can fix any security issues if we have to, but I doubt there'll be any. These people build apps for a living, and they know what they're doing. You worry too much, but that's why you're so good at your job!"
What safeguard can most efficiently ensure that privacy protection is a dimension of relationships with vendors?
What should a privacy professional keep in mind when selecting which metrics to collect?
An executive for a multinational online retail company in the United States is looking for guidance in developing her company's privacy program beyond what is specifically required by law.
What would be the most effective resource for the executive to consult?
During a merger and acquisition, the most comprehensive review of privacy risks and gaps occurs when conducting what activity?
Under the GDPR, what obligation does a data controller or processor have after appointing a data protection officer (DPO)?
SCENARIO
Please use the following to answer the next QUESTION:
Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with her long-time business partner Sadie, Amira has watched the company grow into a major competitor in the green energy market. The current line of products includes wind turbines, solar energy panels, and equipment for geothermal systems. A talented team of developers means that NatGen's line of products will only continue to grow.
With the expansion, Amira and Sadie have received advice from new senior staff members brought on to help manage the company's growth. One recent suggestion has been to combine the legal and security functions of the company to ensure observance of privacy laws and the company's own privacy policy. This sounds overly complicated to Amira, who wants departments to be able to use, collect, store, and dispose of customer data in ways that will best suit their needs. She does not want administrative oversight and complex structuring to get in the way of people doing innovative work.
Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is an unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen will use the best possible equipment for electronic storage of customer and employee data. She simply needs a list of equipment and an estimate of its cost. But the CIO insists that many issues are necessary to consider before the company gets to that stage.
Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust the monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these managers can adjust the company privacy policy according to what works best for their particular departments. NatGen's CEOs know that flexible interpretations of the privacy policy in the name of promoting green energy would be highly unlikely to raise any concerns with their customer base, as long as the data is always used in course of normal business activities.
Perhaps what has been most perplexing to Sadie and Amira has been the CIO's recommendation to institute a
privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy because the employees need no special preparation. They will simply have to document any concerns they hear.
Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate culture strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a unique approach.
What is the most likely reason the Chief Information Officer (CIO) believes that generating a list of needed IT equipment is NOT adequate?
SCENARIO
Please use the following to answer the next QUESTION:
Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with her long-time business partner Sadie, Amira has watched the company grow into a major competitor in the green energy market. The current line of products includes wind turbines, solar energy panels, and equipment for geothermal systems. A talented team of developers means that NatGen's line of products will only continue to grow.
With the expansion, Amira and Sadie have received advice from new senior staff members brought on to help manage the company's growth. One recent suggestion has been to combine the legal and security functions of the company to ensure observance of privacy laws and the company's own privacy policy. This sounds overly complicated to Amira, who wants departments to be able to use, collect, store, and dispose of customer data in ways that will best suit their needs. She does not want administrative oversight and complex structuring to get in the way of people doing innovative work.
Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is an unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen will use the best possible equipment for electronic storage of customer and employee data. She simply needs a list of equipment and an estimate of its cost. But the CIO insists that many issues are necessary to consider before the company gets to that stage.
Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust the monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these managers can adjust the company privacy policy according to what works best for their particular departments. NatGen's CEOs know that flexible interpretations of the privacy policy in the name of promoting green energy would be highly unlikely to raise any concerns with their customer base, as long as the data is always used in course of normal business activities.
Perhaps what has been most perplexing to Sadie and Amira has been the CIO's recommendation to institute a
privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy because the employees need no special preparation. They will simply have to document any concerns they hear.
Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate culture strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a unique approach.
If Amira and Sadie's ideas about adherence to the company's privacy policy go unchecked, the Federal Communications Commission (FCC) could potentially take action against NatGen for what?
What is the key privacy objective in undertaking an evaluation of technical controls?
Which item below best represents how a privacy group can effectively communicate with functional areas?
SCENARIO
Please use the following to answer the next QUESTION:
Ben works in the IT department of IgNight, Inc., a company that designs lighting solutions for its clients. Although IgNight's customer base consists primarily of offices in the US, some individuals have been so impressed by the unique aesthetic and energy-saving design of the light fixtures that they have requested IgNight's installations in their homes across the globe.
One Sunday morning, while using his work laptop to purchase tickets for an upcoming music festival, Ben happens to notice some unusual user activity on company files. From a cursory review, all the data still appears to be where it is meant to be but he can't shake off the feeling that something is not right. He knows that it is a possibility that this could be a colleague performing unscheduled maintenance, but he recalls an email from his company's security team reminding employees to be on alert for attacks from a known group of malicious actors specifically targeting the industry.
Ben is a diligent employee and wants to make sure that he protects the company but he does not want to bother his hard-working colleagues on the weekend. He is going to discuss the matter with this manager first thing in the morning but wants to be prepared so he can demonstrate his knowledge in this area and plead his case for a promotion.
Going forward, what is the best way for IgNight to prepare its IT team to manage these kind of security events?
Incipia Corporation just trained the last of its 300 employees on their new privacy policies and procedures.
If Incipia wanted to analyze the effectiveness of the training over the next 6 months, which form of trend analysis should they use?
Data retention and destruction policies should meet all of the following requirements EXCEPT?
You are the privacy officer at a university. Recently, the police have contacted you as they suspect that one of your students is using a library computer to commit financial fraud. The police would like your assistance in investigating this individual and are requesting computer logs and usage data of the student.
What Is your first step in responding to the request?
Which of the following is TRUE about the Data Protection Impact Assessment (DPIA) process as required under the General Data Protection Regulation (GDPR)?
SCENARIO
Please use the following to answer the next question:
Recently, a boutique fashion company headquartered in California, US needed to fill a very large online order from one of their best customers located in France. The boutique did not have all the items needed to complete the order, so they asked one of their partners located in Canada to help fulfill the order. To save time, the boutique had the items shipped directly from the Canadian partner’s store to the customer’s home address. The partner sent SMS messages to provide the customer with direct shipping updates.
The merchandise arrived to the customer and they were happy with the experience. However, soon after, the customer contacted the boutique to complain that they had been receiving telemarketing calls and emails from other fashion boutiques and stores.
What should the boutique have done to properly handle and govern the customer’s personal information?
You would like to better understand how your organization can demonstrate compliance with international privacy standards and identify gaps for remediation. What steps could you take to achieve this objective?
The General Data Protection Regulation (GDPR) specifies fines that may be levied against data controllers for certain infringements. Which of the following will be subject to administrative fines of up to 10 000 000 EUR, or in the case of an undertaking, up to 2% of the total worldwide annual turnover of the preceding financial year?
TESTED 23 Mar 2026